FS weekly highlights—14 February 2019

FS weekly highlights—14 February 2019

In this issue


Brexit news
Brexit legislation
UK regulators updates
European regulators updates
European System of Financial Supervision
Regulatory architecture
Authorisation, approval and supervision
Prudential requirements
Risk management and controls
Financial crime
FCA conduct requirements
Enforcement and redress
Markets and trading
Regulation of capital markets
Regulation of derivatives
Investment funds and asset management
Banks and mutuals
Consumer credit, mortgage and home finance
Insurance and pensions
Payment services and systems
FinTech and virtual currencies
Sustainable finance
Dates for your diary


Brexit news


ECB publishes opinion on the proposed UK Withdrawal Agreement

The European Central Bank (ECB) published an opinion on a proposal for a Council Decision on the conclusion of the Agreement on the withdrawal of the UK and Northern Ireland from the EU and the European Atomic Energy Community (the Withdrawal Agreement). The opinion follows a request from the Council of the European Union for an opinion on a proposal for a Council Decision on the conclusion of the Withdrawal Agreement (referred to in the opinion as the ‘proposed Decision’). The opinion takes note of the proposed Decision, which approves the Withdrawal Agreement. In particular, the ECB takes note of the provisions of the Withdrawal Agreement on the reimbursement of the paid-in capital provided by the Bank of England (BoE) to the ECB, and the participation of the BoE in the institutional arrangements laid down in Articles 282 and 283 TFEU and the Statute of the European System of Central Banks and the European Central Bank during the transition period.

Treasury Committee publishes correspondence with Economic Secretary to the Treasury on Brexit SIs

The Treasury Committee published a letter sent by Nicky Morgan, Chair of the Committee to the Economic Secretary to the Treasury, John Glen, and his response concerning the evidence Mr Glen gave to the Committee on the Financial Services and Markets Act 2000 (Amendment) (EU Exit) Regulations 2019 (the FSMA SI). In Ms Morgan’s letter, she noted that given the wide range of powers that are being delegated to the BoE, the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) (the Regulators), the Committee felt it was important and necessary that Parliament could scrutinise these additional powers properly. Ms Morgan’s letter also requested further information on Equivalence Determinations for Financial Services and Miscellaneous Provisions (Amendment etc) (EU Exit) Regulations 2019 (Equivalence SI). Mr Glen’s response focused on the Equivalence SI.

ESMA chair on the regulatory challenges of Brexit

On 13 February 2019, chair of the European Securities and Markets Authority (ESMA), Steven Maijoor, gave a speech on ‘Brexit—the regulatory challenges’ at the European Financial Forum 2019 in Dublin, Ireland. Focusing on ESMA's preparations for a no-deal Brexit across a number of areas, including secondary markets, clearing and settlement and cooperation agreements, Mr. Maijoor noted that following Brexit, Europe’s biggest capital market will be moved outside of the EU. He also stated that because the EU27 and UK capital markets are very interconnected, this would be a major operation. According to Mr. Maijoor, carving out the UK capital market requires preparations for all circumstances, by all participants concerned, including the possibility of a no deal Brexit.

Parliament seeks public views on Financial Services (Implementation of Legislation) Bill

The UK Parliament is seeking views on the Financial Services (Implementation of Legislation) [Lords] Bill (the Bill), which is currently passing through Parliament. It published on its website a request for members of the public with relevant expertise and experience or a special interest in the Bill to submit their views in writing to the House of Commons Public Bill Committee, which will be considering the Bill. The Bill enables the Treasury to make corresponding or similar provisions in UK law to upcoming EU financial services legislation in the event that the UK leaves the European Union without a deal. The Bill is now at Second Reading stage in the House of Commons.

Lords Sub-Committee to hear evidence on Brexit and central counterparties

The House of Lords EU Financial Affairs Sub-Committee announced that it will explore the future of Brexit and central counterparties (CCPs) in a one-off evidence session on 13 February 2019 with witnesses from the London Clearing House (LCH) Group and the Futures Industry Association (FIA). Likely questions include:

  • what impact has Brexit had to date on UK CCPs?
  • what is your worst-case Brexit scenario and how ready are CCPs for such a scenario?
  • how could new EU rules in this area affect UK CCPs after Brexit?
Australian securities regulator outlines plans for no-deal Brexit

The Australian Securities and Investments Commission (ASIC) says that it is carefully monitoring developments related to Brexit and is liaising closely with the FCA, the BoE, other Australian financial authorities and the ASIC’s regulated stakeholders to identify and plan for potential Brexit-related impacts. This includes contingency planning in the event that the UK leaves the EU in a ‘no deal’ scenario. In a media release, ASIC Commissioner Sean Hughes said that ASIC’s aim is to limit disruption to Australian financial services and markets. ASIC will continue to monitor developments post-Brexit as intended and unintended consequences become apparent.

ISDA comments on proposed technical standards on Brexit-related novations

The International Swaps and Derivatives Association (ISDA) sent a letter to ESMA and the European Commission on 12 February 2019, commenting on the proposed technical standards on Brexit-related novations. ISDA welcomed the standards that seek to give relief from the margining and clearing requirements to over the counter (OTC) derivative contracts that are transferred (novated) from a UK to an EU counterparty. However, ISDA noted the fact that the relief is contingent on the event of a no-deal Brexit makes it operationally difficult for firms to enter into agreements to novate contracts.

ICMA publishes briefing note on ESMA statement on the use of UK data in ESMA databases and performance of MiFID II calculations in case of a no-deal Brexit

The International Capital Market Association (ICMA) published a briefing note which summarises the key points in ESMA’s statement on the use of UK data in ESMA databases and the performance of MiFID II calculations under a no-deal Brexit with regard to bond markets. ESMA’s statement aims to inform stakeholders on the approach it will take on all ESMA IT applications and databases. 


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Brexit legislation


Occupational and Personal Pension Schemes (Amendment etc) (EU Exit) Regulations 2019

SI 2019/192: This enactment is made in exercise of legislative powers under the European Union (Withdrawal) Act 2018 (EU(W)A 2018) in preparation for Brexit. This enactment makes minor and technical changes to pieces of UK primary and subordinate legislation in the field of occupational and personal pension schemes to ensure retained EU law continues to operate effectively, and to address other deficiencies arising from the withdrawal of the UK from the EU. Part 2 amends primary legislation, Part 3 amends secondary legislation, and Part 4 revokes secondary legislation. It comes into force on exit day (Updated from draft on 8 February 2019). The Occupational and Personal Pension Schemes (Amendment etc) (Northern Ireland) (EU Exit) Regulations 2019 were also updated from draft on 8 February 2019.

Gibraltar (Miscellaneous Amendments) (EU Exit) Regulations 2019

SI 2019/Draft: This draft enactment is laid in exercise of legislative powers under the EU(W)A 2018 in preparation for Brexit. This draft enactment proposes to amend UK subordinate legislation in relation to financial services in order to address deficiencies in domestic legislation and retained EU law, arising from the withdrawal of the UK from the EU. Through amendments to existing UK and EU exit legislation, this instrument ensures that relevant matters in relation to Gibraltar can be treated as they were before exit day to support continued passporting for authorised financial services firms between UK and Gibraltar after exit day.

Updated draft Financial Services Brexit SI: The Financial Services (Miscellaneous) (Amendment) (EU Exit) Regulations 2019 (published 12 February 2019)

The updated draft Financial Services (Miscellaneous) (Amendment) (EU Exit) Regulations 2019 published by HM Treasury on 12 February 2019 makes minor amendments to the previous draft published on 5 February 2019 (format changes and an amendment to remove the reference to ‘exit day’ in relation to the Credit Institutions and Insurance Undertakings Reorganisation and Winding Up (Amendment) (EU Exit) Regulations 2019). The SI addresses deficiencies in UK domestic law and retained EU law arising from the UK’s withdrawal from the EU in line with the approach taken in other financial services EU exit instruments under the EU (Withdrawal) Act 2018 (EUWA). Additionally the SI also revokes a number of pieces of retained EU law and UK domestic law which would be inappropriate to keep on the statute book after exit as they deal with cross-border activity in the EU and the functioning of EU institutions.

Draft Public Record, Disclosure of Information and Co-operation (Financial Services) (Amendment) (EU Exit) Regulations 2019—correction slip 12 February 2019

On 9 January 2019, HM Treasury published the draft Public Record, Disclosure of Information and Co-operation (Financial Services) (Amendment) (EU Exit) Regulations 2019 together with explanatory information. On 12 February 2019, a correction slip to the draft SI was published. The amendments renumber paragraphs and change some of the references to EU legislation to ‘relevant directives’ and ‘relevant provisions’. The SI’s purpose is to make amendments to domestic legislation and retained EU law relating to the disclosure of confidential information to ensure that the legal framework can operate effectively in a UK context once the UK leaves the EU, in any scenario.

Brexit SI Bulletin—latest drafts and sifting committee recommendations, 8 February 2019

The Commons European Statutory Instruments Committee (ESIC) and the Lords Secondary Legislation Scrutiny Committee (SLSC) are responsible for the sifting process under the EU(W)A 2018. These committees scrutinise proposed negative Brexit SIs and make recommendations on the appropriate parliamentary procedure before the instruments are laid in Parliament. This bulletin outlines the latest updates and recommendations, collated on 8 February 2019. The following Brexit SIs were noted to be of interest by SLSC Sub-Committee A and Sub-Committee B:


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UK regulators updates


FCA published guidance consultation and finalised guidance in Primary Market Bulletin No. 20

The FCA published Primary Market Bulletin No. 20, which contains guidance consultation 19/1 (GC19/1), which consults on changes that the FCA is proposing to make to the Knowledge Base, and finalised guidance 19/1 (FG19/1), which sets new and amended guidance in relation to the Knowledge Base. The Knowledge Base is the FCA's repository of non-handbook commentary that enjoys the status of formal FCA guidance. It consists of a series of short procedural and technical notes published in PDF format and ordered by topic. The notes relate to aspects of the Listing Rules, Prospectus Rules and Disclosure Guidance and Transparency Rules.

PRA publishes Policy Statement (PS 3/19) on changes to periodic transaction fees

On 13 February 2019, the PRA published Policy Statement (PS 3/19) to provide feedback to responses to Consultation Paper (CP 28/18) ‘PRA fees and levies: Changes to periodic and transaction fees’. PS 3/19 is relevant to all PRA-regulated firms, but particularly insurers and designated investment firms, as well as firms which applying, or intending to apply in the future for, Solvency II or Capital Requirements Regulation (CRR) models. The PRA received four responses to the CP. The feedback to these responses is set out in Chapter 2 of PS 3/19. The implementation date for the ‘PRA Fees Amendment Instrument 2019’ and the updated SS3/16 ‘Fees: PRA approach and application’ is Friday 1 March 2019.

FCA publishes video guides to help claims management companies get ready for regulation

The FCA published a series of step-by-step video guides to help claims management companies (CMCs) find out what they need to do to get ready for FCA regulation. The FCA will become the regulator of CMCs on 1 April 2019. The FCA published three video guides on the following topics:

  • introduction to FCA regulation: Garry Hunter, head of CMC Regulation, explains what CMCs need to do to get ready for FCA regulation
  • five things CMCs need to know to get ready for regulation, and
  • how to register for temporary permission


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European regulators updates


European Commission call for advice to ESAs regarding undue short-term pressure from financial sector on corporations

The European Commission published a call for advice, in which it invites each of the European Supervisory Authorities (ESAs) to develop a report presenting the evidence and possible advice on potential undue short-term pressure on corporations. The ESAs are expected to assess the extent to which short-termism is present and can be considered problematic. The ESAs should investigate potential sources of such pressure on corporates stemming from the financial sector. If evidence reveals significant issues, the Commission also invites the ESAs to assess whether these issues could be addressed by regulators and to provide advice on areas which regulators should address.

Council of the EU provides update on progress on EU financial services legislative files

The Council of the EU published an update on progress of EU financial services legislative files. The update lists the legislative files, the date of first presentation by the Commission and the current state of play. The note provides an update on a number of important legislative proposals including:

  • the European Market Infrastructure Regulation (EMIR REFIT) (Current status: Political Agreement: February 2019)
  • the regulations on ESAs and related legislation (Current status: Review in the Council WP ongoing—Partial mandate on Anti-Money Laundering), and
  • the Sustainable finance framework (Current status: Review in the Council WP ongoing)
Approval of consultation procedure to appoint executive board member to ECB

Draft letters from the President of the European Council addressed to the President of the European Parliament and to the President of the ECB respectively, were published by the Council in order to approve the appointment of a member of the executive board of the ECB. The Council Recommendation (5940/19) and the CV of Mr Philip R. Lane are to be enclosed in the letters. Mr Lane currently serves as the Governor of the Irish Central Bank and was also recently nominated to serve as the next Chief Economist of the ECB.

ESMA publishes its 2019 Risk Assessment Work Programme

ESMA published its Risk Assessment Work Programme, providing an overview of the analytical, research, data and statistical activities that ESMA will carry out in 2019. The 2019 Risk Assessment Work Programme is one of ESMA's activity reporting documents, the others are the Regulatory Work Programme, the Supervisory Work Programme and the Supervisory Convergence Work Programme. Also, ESMA is preparing for any changes to its analytical and statistical framework that may need to be made when the UK leaves the EU. 


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European System of Financial Supervision


Presidency calls for Council of EU to agree position on entire ESFS package

The Romanian Presidency of the Council of the EU called on the Council to agree on its general approach on the European Commission’s entire package of legislative proposals regarding the European System of Financial Supervision (ESFS) and to invite the Presidency to start, as soon as possible, negotiations with the European Parliament on the basis of the complete ESFS mandate with a view to reaching an agreement at first reading. On 20 September 2017, the Commission presented its package of legislative proposals on the ESFS. An anti-money laundering (AML) component was further added by the Commission to this legislative package with a proposal issued on 12 September 2018. On 19 December 2018, the Permanent Representatives Committee (Coreper) agreed on a partial mandate for negotiations on the AML component, while leaving the remainder of the ESFS file for continued discussion in the Council.

Council of EU confirms position on ESFS review ahead of negotiations with European Parliament

The Council of the EU confirmed its position on proposals to review the functioning of the current ESFS, inviting the Romanian presidency to start negotiations with the European Parliament as soon as possible. Following this confirmation of the Council’s general approach, both co-legislators are now ready to start trilogue negotiations on the basis of the complete ESFS mandate, and the first trilogue is scheduled to take place on 14 February 2019. The Council was examining the proposals at a technical level since October 2017, and its position published today clarifies a number of issues such as the Council’s desire to generally preserve the existing system of contributions coming partly from the EU budget and partly from national competent authorities.

House of Commons European Scrutiny Committee retains scrutiny over proposed ESFS reforms

The House of Commons European Scrutiny Committee published its 54th report, in which it summarises its review and conclusions of EU documents considered by the Committee on 6 February 2019. Documents considered include the Commission’s proposed changes to the ESFS. The Committee considered the ongoing review of the ESFS and concluded that it is directly relevant to the UK financial services industry both before and after the UK leaves the EU. Given the potential implications of the proposals for the UK, the Committee welcomed the indications that the Member States at least want to significantly alter some of the more far-reaching elements of the original Commission proposal.


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Regulatory architecture


FSB publishes 2019 work programme

The Financial Stability Board (FSB) published its work programme for 2019, setting out its planned work and an indicative timetable of its main publications for 2019. The FSB’s focus was on shifting from post-crisis policy design to implementing and evaluating the effects of the reforms and monitoring vigilantly any new and emerging risks to financial stability, and this change is reflected in the 2019 work programme. The FSB’s main areas of work for 2019 are (1) addressing new and emerging vulnerabilities in the financial system (2) finalising and operationalising post-crisis reforms (3) implementation of reforms, and (4) evaluating the effects of the reforms.

TheCityUK appoints Mark Tucker as Chairman of its Board

TheCityUK appointed Mark Tucker, Group Chairman of HSBC, as the new Chairman of its Board, succeeding John McFarlane, who will step down on 31 May 2019. Mark Tucker, Chairman Designate, TheCityUK, said "I am very pleased to succeed John and to have the opportunity to lead TheCityUK Board at such an important time for the industry. We are facing a period of transformation driven by changing international relationships and technology and we must work together to secure the future of the UK’s international competitiveness". 


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Authorisation, approval and supervision


FCA video shows banking leaders share their insights on adopting the SM&CR

The FCA published a new video in which senior leaders from four financial services firms, together employing over half a million staff, talk about their experiences of adopting the Senior Managers and Certification Regime (SM&CR). The SM&CR aims to increase individual accountability within financial services and is a key step to improve culture and governance in the sector. It was first adopted by the banking sector in 2016 and by insurers in December 2018. The FCA will be extending the SM&CR to around 47,000 solo-regulated firms in December 2019.

PIMFA Launches Diversity Conference to Help Tackle Diversity & Inclusion Gap in Financial Services

The Personal Investment Management and Financial Advice Association (PIMFA) launched its inaugural Wealth of Diversity Conference. The conference, sponsored by EY, addressed key initiatives to promote diversity and inclusion, and gave insights into best practice for promoting culture and diversity in the workplace. The day was opened by keynote speaker John Glen MP, UK Economic Secretary to the Treasury and City Minister, who highlighted the importance of diversity and inclusion and reemphasised the government's commitment to these issues. 


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Prudential requirements


ESRB recommends EU-wide reciprocation of France’s 5% large exposure limit for highly indebted large NFCs

The European Systemic Risk Board (ESRB) issued a press release on its recommendation for the EU-wide reciprocation of France’s 5% large exposure limit for exposures of systemically important institutions (SIIs) to highly indebted large non-financial corporations having their registered office in France. This recommendation was adopted by the ESRB on 5 December 2018 and published in the Official Journal of the EU on 1 February 2019. The ESRB’s recommendation seeks to ensure that France’s 5% large exposure limit applies not only to exposures of SIIs authorised in France, but also to exposures of SIIs authorised in other EU Member States. It thereby enhances the effectiveness and consistency of macroprudential policy in the EU and contributes to a level playing field in the Single Market. 


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Risk management and controls


Government updates EU Committee and European Scrutiny Committee on progress of proposed Whistleblowing Directive

The government published two letters sent by Kelly Tolhurst, Minister for Small Business, Consumers and Responsibility, to the European Union Committee and the European Scrutiny Committee regarding progress of EU negotiations on the proposed Directive on whistleblowing. In the letters, the government gives an update on the negotiations and its views on the proposed text, and addresses questions raised by the European Union Committee. In updating the Committees on the negotiations, the government confirms that the proposed Directive progressed rapidly through negotiations in working parties, and on 25 January 2019, the Presidency was granted a mandate to proceed with trilogues with the European Parliament. The Presidency indicated that it intends to hold a formal vote for a General Approach at the Justice and Home Affairs Council meeting on 7-8 March 2019.

RBC owes fired London whistleblower £1.2M, tribunal says

An employment tribunal in London ordered Royal Bank of Canada (RBC) to pay a former currency trader around £1.2m ($1.3m) after he was found to be unfairly dismissed for repeatedly making complaints about the lender's compliance culture. The tribunal's decision, which was made available on 4 February, said that John Banerjee, who lost his job after blowing the whistle on alleged lapses in RBC's compliance procedures at the Toronto-based bank's London operation, should be compensated around £1.2m to cover lost earnings. The former foreign exchange trader earned £280,000 a year, including a bonus, when he lost his job in 2016, court documents show. Judge James Tayler, who sat on the tribunal, based his decision to award £1.2m on the calculation that Banerjee would retire as a trader at RBC in 2021.

GFMA publishes voluntary financial data handling principles based on GDPR

The Global Financial Markets Association (GFMA) published its Financial Data Handling Principles for Banks and Non-Banks, a set of voluntary principles drawn from international best practices. The principles are based on the US National Institute of Standards and Technology Cybersecurity Framework and the EU’s General Data Protection Regulation (GDPR). 


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Financial crime


European Commission adopts new list of third countries with weak AML and ATF regimes

On 13 February 2019, the Commission adopted a new list of 23 third countries with strategic deficiencies in their AML and anti-terrorist financing (ATF) frameworks. As a result of the listing, banks and other entities covered by EU AML rules will be required to apply due diligence on financial operations involving customers and financial institutions from these high-risk third countries to identify any suspicious money flows. A new methodology, which reflects the stricter criteria of the Fifth Anti-Money Laundering Directive in force since July 2018, was used to create the list following an in-depth analysis.

European Parliament and Council of EU reach political agreement on law enforcement access to financial information

The European Parliament and the Council of the EU reached a political agreement on the European Commission’s proposal to facilitate cross-border access to financial information by law enforcement authorities, to ensure timely access to the necessary information to prevent and investigate terrorism and other serious crime. The agreement was welcomed by the European Commission, which proposed the new measures in April 2018. The agreed measures will complement the existing Fourth Money Laundering Directive, which was designed to strengthen the EU’s defences against money laundering and terrorist financing.

MEPs conclude first leg of Danske Bank scandal fact-finding mission

The European Parliament published a press release noting that a delegation of MEPs from the European Parliament's special committee on financial crime, tax evasion and tax avoidance concluded its Estonian leg of its fact-finding mission. In Estonia, the delegation met with journalists, national authorities and representatives of Danske Bank Estonia, the branch responsible for the bulk of the money laundering scandal Danske Bank is currently faced with. The delegation now moves on to Denmark to continue its investigations there.

Committee publishes letter from FOS about economic crime

On 13 February 2019, the Treasury Committee took evidence from UK Finance, Santander UK and Nationwide Building Society as part of its inquiry into economic crime. Before the evidence session, the Committee published a letter from the Financial Ombudsman Service (FOS), part of which focusses on economic crime. Caroline Wayman, Chief Ombudsman and Chief Executive of the FOS, says in the letter that the FOS received 8,500 complaints about fraud and scams in 2017/18, and already received over 10,000 new cases this financial year.

Fraudster families running multimillion pound pension scams

Organised crime groups led by married couples or families are running pension scams worth millions of pounds, according to intelligence gathered by members of the multi-agency Project Bloom group, which was set up to tackle pension scams. Criminal investigations involving regulators, government agencies and police forces are currently ongoing into a number of these gangs. In addition, a number of individuals linked to the scams are being suspended or banned from acting as trustees and companies used for scams are being shut down.

Ex-Moldova PM's son forfeits cash after NCA probe

British investigators seized more than £466,000 ($601,000) from three frozen bank accounts belonging to the son of a jailed former Moldovan Prime Minister, the National Crime Agency (NCA) said, after suspecting that the funds originated from a $1bn money laundering scandal. Vlad Luca Filat, 22, was stripped of nearly half a million pounds after Judge Michael Snow granted forfeiture orders on his accounts during a hearing at the City of London Magistrates Court. Judge Snow agreed with the  NCA that the money was likely connected to the disappearance of $1bn from three Moldovan banks in 2014 for which his father is serving nine years in jail. ‘I am satisfied on the balance of probabilities that the cash was derived from his father's criminal conduct in Moldova’ Judge Snow said.

Petrofac faces shareholder litigation over corruption claims
Corruption allegations surrounding Petrofac threatened to spill into the English civil courts as a litigation funder said it is preparing to back shareholders in a claim against the oil services company, which is already under investigation by the Serious Fraud Office (SFO). Innsworth Litigation Funding and a law firm, Keystone Law, are assembling institutional shareholders who bought or held shares in Petrofac starting from October 2010. They are ‘well progressed in their analysis of potential claims,’ Innsworth said in a statement. It is understood that claims against Petrofac, which is registered in the offshore UK dependency of Jersey, could exceed £400m ($516m). Lawyers hope to file suit in April or May, after they complete their investigations.


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FCA conduct requirements


FCA to announce next steps in work on potential duty of care in spring 2019

The FCA updated its webpage on its discussion paper on a duty of care for financial services firms and potential alternative approaches (DP18/5) on 5 February 2019 by adding a new ‘next steps’ section to the webpage. The FCA published DP18/5 in July 2018, alongside a document setting out its approach to consumers (see Legal update, FCA approach to consumers and discussion paper on a new duty of care). DP18/5 closed to responses in November 2018.

FCA modification by consent for employers' liability register compliance reporting

The FCA published a direction regarding a modification by consent of a rule in its Supervision manual (SUP) for employers’ liability register compliance reporting. The modification relates to SUP 16.23A.6, which applies to firms which are required to produce an employers’ liability register in compliance with the requirements in ICOBS 8.4.4R of the FCA Handbook. 


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Enforcement and redress


CMA launches consultation on draft Investment Consultancy and Fiduciary Management Market Investigation Order 2019

The Competition & Markets Authority (CMA) gave notice of its intention to make the Investment Consultancy and Fiduciary Management Market Investigation Order 2019 (the Order) and published a draft of the Order and a draft Explanatory NoteRepresentations on the draft Order and Explanatory Note should be in writing and should reach the CMA by 10 a.m on Wednesday 13 March 2019. The CMA published its findings in the Investment Consultants Market Investigation Final Report published on 12 December 2018. The Final Report set out the CMA’s findings that there are features of the markets for Investment Consultancy Services and Fiduciary Management Service, which individually and in any combination adversely affect competition in connection with the supply and acquisition of those services in the UK to and by pension schemes. The CMA decided on a package of remedies to be implemented by it in order to remedy, mitigate or prevent the adverse effects on competition that it found and the detrimental effect on customers that may be expected to result—the Order will give effect to these remedies.

FCA begins High Court proceedings against Samuel Golding, Shantelle Golding, Digital Wealth Limited and Outsourcing Express Limited
The FCA confirmed the start of High Court proceedings against Samuel Golding, Shantelle Golding and two of their companies, Digital Wealth Limited and Outsourcing Express Limited (the Defendants). The FCA is seeking a declaration that the Defendants contravened, or were knowingly concerned in contraventions of, sections 19 and 21 of the Financial Services and Markets Act 2000 (FSMA 2000). FSMA, s 19 contains the general prohibition against carrying on (or purporting to carry on) a regulated activity in the UK without authorisation or exemption. FSMA, s 21 contains restrictions on financial promotion.


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Markets and trading


FSB publishes responses to consultation on financial resources for CCPs in resolution

The FSB published responses to its discussion paper on proposed financial resources to support CCP resolution and the treatment of CCP equity in resolution. The consultation was launched on 15 November 2018 and closed on 1 February 2019. The FSB concluded in 2018 that further guidance on the necessary financial resources should be developed in an evidence-based way including by drawing on the practical experience gained from resolution planning by relevant authorities and crisis management groups. The FSB expects to publish further guidance for public consultation in 2020.

EMMI publishes stakeholder feedback to Second Public Consultation on Hybrid Methodology for EURIBOR

The European Money Markets Institute (EMMI) published a summary of stakeholder feedback received to its second consultation paper on a hybrid methodology for EURIBOR, along with a blueprint of the methodology. The consultation presented EMMI’s findings from its hybrid EURIBOR testing phase to test its proposed hybrid methodology for EURIBOR. The consultation period closed on 30 November 2018 and EMMI says the responses showed ‘broad support’ for its proposals. This was EMMI’s second consultation on its proposed hybrid methodology for EURIBOR and is part of EMMI’s commitment to deliver a reformed and robust methodology for EURIBOR, which aims to meet regulatory and stakeholder expectations in a timely manner.

FCA publishes market abuse speech

The FCA published a speech given by Julia Hoggett, director of market oversight at the FCA, at the Association for Financial Markets in Europe (AFME) ‘Implementation of the Market Abuse Regulation in the UK’ event, London. The speech focused on some of the specific issues that the FCA is concerned about in relation to market abuse. The speech also aimed to help frame how market participants should think about the risk of market abuse taking place and add some colour to recent FCA publications on the subject in Market Watch. During her speech, Ms Hoggett touched on the FCA’s five conduct questions approach. The approach serves as a conduct risk mitigation framework that is increasingly used across FCA Wholesale Supervision and which helps regulated firms enhance the manner in which they conduct business.

CLLS responds to FCA consultation on restricting CFD products sold to retail clients

The City of London Law Society (CLLS) published its Regulatory Law Committee’s response to FCA consultation 18/38 (CP18/38) on restricting contract for difference (CFD) products sold to retail clients. The response recommends that the proposed definition of ‘restricted option’ set out in CP18/38 should be reconsidered, as it contains some significant elements of uncertainty and risks capturing unintended targets and missing some intended targets. In its response, the CLLS highlights the significant impact of the product intervention proposals in respect of CFD-like options, which means that the proposed definition of ‘restricted option’ must be as certain as possible. 


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MiFID II—rules to further specify the calculation of the minimum tick sizes for financial instruments

The European Commission adopted a Delegated Regulation amending Delegated Regulation (EU) 2017/588 as regards the possibility to adjust the average daily number of transactions for a share where the trading venue with the highest turnover of that share is located outside of the EU. Article 49 of MiFID II obliges trading venues to adopt tick size rules for shares, depositary receipts, certain exchange traded funds, certificates and similar financial instruments. Tick sizes should be calibrated to reflect the liquidity of the financial instrument in the markets where the instrument is traded. The tick size needs to be determined for each financial instrument individually. Article 49(3) of MiFID II requires ESMA to develop draft regulatory technical standards to further specify tick sizes or tick size regimes for the instruments mentioned above.

ESMA delays publication of MiFIR double volume cap data

ESMA announced it decided to delay the publication of the double volume cap (DVC) data foreseen for 7 February 2019 due to a technical issue with the DVC system. Instead this publication is planned for 15 February 2019. As set forth in Article 5 of MiFIR, the DVC mechanism aims to limit the trading under the reference price waiver and the negotiated transaction waiver for liquid instruments in an equity instrument. ESMA regularly publishes DVC data on its website. The latest update was published on 9 January 2019.

TISA updates guide on MiFID II costs and charges disclosures

The Tax Incentivised Savings Association (TISA) published an updated version of its MiFID II implementation guide for costs and charges disclosures. The new version includes guidance to clarify the standards and methodologies when completing the ex post section of the European MiFID template, as well as guidance on ex post cumulative effect of charges on returns. TISA is a cross-industry body with over 200 member firms from all areas of UK financial services. Produced to assist asset management and distribution firms, its guide sets out a comprehensive, industry-wide approach to the practical aspects of implementing the costs and charges provisions of MiFID II, including suggested templates. 


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Regulation of capital markets


ESAs publish final recommendations on PRIIPs KIDs

The ESAs published their final recommendations following a consultation on targeted amendments to Commission Delegated Regulation (EU) 2017/653 covering the rules for the key information document (KID) for packaged retail and insurance-based investment products (PRIIPs). The ESA decided not to propose targeted amendments at this stage, but to undertake a more comprehensive revision of the PRIIPs Delegated Regulation in the course of 2019. The ESAs reached their decision taking into account the feedback on their consultation and considering in particular the implications of a possible decision by the European co-legislators to defer the application of the KID by certain types of investment funds beyond 2020.

ESMA publishes list of national thresholds below which a prospectus is not required

ESMA published a document listing the thresholds below which an offer of securities to the public does not need a prospectus in the various EU Member States under the Prospectus Regulation (EU) 2017/1129. ESMA drew up this document to create transparency around the regimes adopted across the EU. The Prospectus Regulation introduces a new threshold below which an offer does not require a prospectus. This threshold is €1m. Member States may decide to raise that threshold to a maximum of €8m, provided that an offer will not be passported to another Member State.

IOSCO members report having mostly implemented secondary market principles
The International Organisation of Securities Commissions (IOSCO) published a report by its Assessment Committee (AC) entitled, 'IOSCO Standards Implementation Monitoring on Secondary and Other Market Principles'. The report indicates that the member jurisdictions included in the AC’s review mostly implemented the IOSCO Secondary and Other Market Principles, which form part of IOSCO’s essential regulatory framework for securities regulations. The main objective of the review carried out by the AC was to gain a global overview of the status of implementation of each of the five Secondary and Other Market Principles by participating member jurisdictions based on their self-assessments. 


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Regulation of derivatives


IOSCO practices aim to create robust framework for commodities' storage and delivery

IOSCO published a report which sets out good or sound practices to assist relevant storage infrastructures and their oversight bodies to identify and address issues that could influence the pricing of commodity derivatives and in turn affect market integrity and efficiency. This document builds on the findings that are set out in the report, 'The Impact of Storage and Delivery Infrastructure on Derivatives Market Pricing' (Storage Report), which was published by IOSCO on May 9, 2016.

ISDA 2019 German Bank CDS Protocol

ISDA published its ISDA 2019 German Bank CDS Protocol (the Protocol) to enable parties to Protocol Covered Transactions to amend the terms of such Protocol Covered Transactions. The Protocol is relevant for parties that entered into credit derivatives transactions referencing German banks.

ISDA publishes updated Commodities Derivatives Disclosure Annex
ISDA published an updated version of its Commodities Derivatives Disclosure Annex. The updated disclosure annex, which is one of several US Commodity Futures Trading Commission (CFTC) disclosure documents published by ISDA, is available on the ISDA website. 


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Investment funds and asset management


Fiduciaries, secret commissions-existence of relationship and scope of duties (Medsted Associates Ltd v Canaccord Genuity Wealth (International) Ltd)

Canaccord (formerly Collins Stewart), a second-tier provider of contracts for differences contracted with a broker, Medsted, under which Collins Stewart was required to pay commission to Medsted in respect of investors introduced by Medsted. In breach of that contract, Collins Stewart did business directly with certain investors, thereby depriving Medsted of the commission to which it was entitled. At first instance the judge found that Medsted suffered loss, but, on public policy grounds, awarded only nominal damages to Medsted, on the basis that Medsted was a fiduciary which breached its fiduciary duties to the investors by failing to disclose the amount of commission it received from Collins Stewart. The Court of Appeal  found: (a) that Medsted was a fiduciary, but (b) that, in the circumstances of the case, the scope of its duties did not extend so far as to require it to reveal the extent of its commission. It therefore allowed the appeal and made an order for damages to be assessed.

ESMA keynote address at 7th annual cross-border distribution conference

ESMA Executive Director, Verena Ross, delivered a key note speech at the 7th annual cross-border distribution conference on 12 February 2019. Ms. Ross noted that it is essential to maintain investors’ confidence that the sector is working for them and that investors are protected no matter where they are based in the EU. She noted that this is where ESMA’s measures to promote investor protection and supervisory convergence are crucial. She noted also that the asset management sector plays, and will continue to play, a key role ensuring a stable financial system and sustainable growth in the European Union.

FCA paper says regulators should encourage funds to focus on corporate governance

The FCA published a research note reviewing recent academic research on the impact of the growth of passive investing on market efficiency and market effectiveness. The paper suggests that, rather than examining the asset management market from a strictly investor protection perspective, regulators should design a regime that encourages both active and passive funds to focus more on corporate governance. The paper acknowledges that the growth of passive investing created substantial benefits for investors but argues that active fund management can also create substantial benefits.

Fund markets dip in 2018 as savers react to uncertainty
The Investment Association (IA), the trade body that represents UK asset managers, published figures on how savers invested in 2018. The figures show that net retail sales for 2018 were £7.2b, in comparison to £48.5b in 2017. UK equity funds saw net retail outflows of £4.9b in 2018. Global was the best-selling sector of 2018 with net retail sales of £3.9b. Chris Cummings, Chief Executive of the IA, said: ‘Savers faced a perfect storm of political and economic uncertainty during 2018, leading to a sharp drop in retail fund sales. With investor confidence dented, the fund market experienced a dip, ending the year with £1.15t funds under management’.


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Banks and mutuals


European Parliament publishes briefing on completing the Banking Union

The European Parliament published a briefing which gives an overview of the state of play of the various work streams on completing the Banking Union, covering both risk sharing (European Deposit Insurance Scheme (EDIS)) and risk reduction measures—this briefing is regularly updated. The briefing sets out the Capital Markets Union milestones reached so far since the publication of the Five Presidents’ Report on 22 June 2015. On 24 November 2015, the Commission put forward a Proposal on a EDIS presented as the third pillar of the Banking Union and a Communication ‘Towards the completion of the Banking Union’, which identifies a number of risk reduction measures seen as counterbalancing measures to EDIS. Given the lack of consensus on a number of key aspects of these files, the EDIS proposal is still being discussed in the European Parliament and in the Council.

ECB speech—risks to banks from inside and out
The ECB published a  speech by Sabine Lautenschläger, Member of the Executive Board of the ECB, at the 14th Asia-Pacific High-level meeting on Banking Supervision, in Sydney, Australia on 13 February 2019. Ms. Lautenschläger divided her speech into a discussion of risks to banks from the outside, ie risks stemming from the economy, geopolitics and technology, and risks to banks from the inside, ie risks stemming from governance, culture and ethics. With respect to outside risks, Ms. Lautenschläger looked first at the risk created by non-performing loans (NPL), noting that in early 2015, significant institutions in the Euro area held almost €1trn worth of bad loans on their balance sheets. She stated that NPLs require special care and so tie up management resources. They also pose a higher risk of losses, require provisions, tie up capital and affect lending. Their effect on lending is what makes NPLs a problem that reaches beyond the banks.


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Consumer credit, mortgage and home finance


Treasury Committee hears evidence on consumers’ access to financial services

The House of Commons Treasury Committee published oral evidence given on 5 February 2019 as part of its inquiry into consumers’ access to financial services. Evidence was given by founder and chief executive of Monzo Bank Tom Blomfield, managing director of Lloyds Bank and Bank of Scotland Community Banks Robin Bulloch, and banking director of the Post Office Martin Kearsley. The inquiry looks at consumers’ access to financial services and as part of its scope will consider whether vulnerable consumers can access appropriate and affordable credit.

FCA data show a mortgage market in flux

The FCA published proprietary data on the mortgage market, which paint a picture of an evolving sector. According to the data, the proportion of borrowers who will be aged over 66 when their mortgages mature is on the rise, while the average age of first-time buyers changed very little. Rates of re-mortgaging and lending to the self-employed are on the rise but remain below pre-crisis levels. In 2015, 26% of all mortgages were due to mature when the borrower was 66 or older. In 2018, that figure had risen to 30%, an increase of almost 411,000 mortgages. In the great majority of cases (94%) the increase will see the mortgage mature when the borrower is aged between 66 and 70. 


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Insurance and pensions


Technical information for Solvency II reporting published in Official Journal

Commission Implementing Regulation (EU) 2019/228 of 7 February 2019 laying down technical information for the calculation of technical provisions and basic own funds for reporting with reference dates from 31 December 2018 until 30 March 2019 in accordance with Solvency II was published in the Official Journal.

EIOPA publishes Commission letters on Solvency II

The European Insurance and Occupational Pensions Authority (EIOPA) published letters dated 1 and 7 February 2019 from the European Commission. The letter dated 1 February 2019 is a response to EIOPA’s letter of 10 December 2018 on the public consultation concerning the draft delegated act on the review of the Solvency II implementing measures. The letter dated 7 February 2019 requests EIOPA to review the methodology for the activation of the country component of the volatility adjustment under Solvency II.

EIOPA updates Q&As on regulation

EIOPA updated its Q&As on the Solvency II regulation. The new Q&As relate to the templates for submission of information to the supervisory authorities. EIOPA’s Q&As under the same sub-topic include:

  • Answers to (EU) No 2015-2011 lists of regional governments local authorities exposures
  • Answers to (EU) No 2015-2452 procedures formats and templates of the solvency and financial condition report, and
  • Answers to (EU) No 2015-2451 with regard to internal models
IE updates online consumer focus tool

Insurance Europe (IE) published an update to its online consumer focus tool, which outlines examples of the work undertaken by Europe’s insurers to provide innovative products and services for consumers. This tool provides information through an interactive map of Europe that allows users to click on specific countries to gain insight into insurers’ consumer-focused practices in that particular market. The tool provides examples of initiatives in several important areas, including digitalisation, enhanced claims management and initiatives to fight insurance fraud.

Council of the EU confirms agreement on PEPP

EU ambassadors endorsed the agreement reached between the presidency and the European Parliament on 13 December 2018 on the proposed 'pan-European pension product' (PEPP). The new regulation now needs to be formally adopted by the European Parliament and the Council before it can enter into force. The draft regulation is aimed at providing greater choice for people who wish to save for their retirement, whilst boosting the market for personal pensions. According to the European Commission, only 27% of Europeans between 25 and 59 years of age are subscribed to a pension product.

John Glen updates parliamentary committees on proposed PEPP Regulation

HM Treasury published letters from John Glen to the House of Commons European Scrutiny Committee and the  House of Lords European Union Committee providing updates on the proposal for a Regulation on PEPP. The letters summarise the results of the trilogue negotiations on key aspects of the Regulation (authorisation of PEPPs, the introduction of a charge cap on the basic PEPP product, the tax treatment of PEPPs and a mandatory advice requirement on PEPPS) and seek clearance for the UK to be able to vote in favour of the final Regulation in Council.

Council of the EU publishes ‘I’ item note on proposed PEPP Regulation

The Council of the EU published an ‘I’ item note on the proposal for a Regulation on PEPP. Provisional agreement on the text of the Regulation was reached by the Council of the EU, the European Parliament and the Commission on 13 December 2018. The note sets out the final compromise text of the proposed Regulation and invites the Coreper to approve the agreed text and to confirm that the proposed Regulation may be adopted if approved by the European Parliament in the agreed form.

ABI responds to DWP consultation on the consolidation of defined benefit pension schemes

The Association of British Insurers (ABI) published its response to the Department for Work and Pensions (DWP) consultation on the consolidation of defined benefit pension schemes. In its response, the ABI warns that allowing these ‘superfunds’ to operate for-profit consolidators under an untested, light-touch regulatory regime risks playing ‘retirement roulette’ with scheme member benefits. The DWP consultation was launched on 7 December 2018 and closed on 1 February 2019. It sought views on a new legislative framework for authorising and regulating defined benefit ‘superfund’ consolidation schemes. According to the government, consolidating defined benefit pension schemes into superfund entities so that they benefit from improved funding, economies of scale and better governance would provide more security for members of some pension schemes.

Seven years in jail for bosses who recklessly risk pensions

A new criminal offence of ‘wilful or reckless behaviour’ in relation to pensions will be introduced under proposals to crack down on abuse of final or average salary schemes. The intention to introduce a new criminal offence, and the recommended maximum sentence of up to seven years’ imprisonment or an unlimited fine, is included in the government’s response to a consultation on enhancing The Pensions Regulator’s (TPR’s) powers. The government consultation on plans to improve TPR’s powers and increase the protections for defined benefit pension scheme members ran from 26 June 2018 to 21 August 2018.

TPR welcomes new powers following DWP announcement

TPR published a statement welcoming the DWP’s announcement of new powers for TPR. TPR’s comments follow the publication of DWP’s response to its 2018 consultation on plans to improve TPR’s powers and increase the protections for defined benefit (DB) pension scheme members. TPR, the UK’s regulator of work-based pension schemes, confirmed that it is working closely with the government to ensure that the new legislation is effective and works in practice.


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Payment services and systems


EBA launches new working group on APIs under PSD2

The European Banking Authority (EBA) published a new webpage with information on the working group on Application Programming Interfaces (APIs) under the Payment Services Directive (EU) 2015/2366 (PSD2). The working group will be chaired by the EBA and composed of representatives from a variety of external stakeholders. The working group is composed of an equal number of nine representatives each from Account Servicing Payment Service Providers, Third Party Providers, and API initiatives respectively, and a smaller number of other representatives from standardisation bodies, technical service providers and payment service users.

PSR consults on pass-through analysis for market review of card-acquiring services

The Payment Systems Regulator (PSR) launched a consultation on its proposed approach to analysing how the level of fees that merchants pay for card-acquiring services responded to changes in interchange fees and scheme fees, as part of its market review into the supply of card-acquiring services. The deadline for comments is 1 March 2019. The final terms of reference (ToR) of the PSR’s market review were published on 24 January 2019. The ToR state that the PSR will examine how the level of the fees merchants pay for card-acquiring services responded to changes in the fees acquirers pay to card system operators (scheme fees) and card issuers (interchange fees).

Government urged to guarantee consumers' ability to access their cash

During a Treasury Committee evidence session held today, the Chair of the PSR, Charles Randell, said that the whole system of access to cash needs to be looked at afresh, and that the PSR board will indeed look at the entire infrastructure of cash provision. Mr Randell’s comments came in response to Rt Hon. Nicky Morgan MP’s request for information on the future of the UK’s ATM network. Mr. Randell noted that because changes to the way people use cash and contactless payments affected the economics of the cash distribution industry, there should be a debate within the industry in 2019 about whether access to cash should be a universal service, rather than a commercial one.

Consumer body calls for regulator to protect cash-users

The government must appoint a new regulator to protect the interests of more than 25 million people who rely on cash, a consumer group said, warning that bank branch and cashpoint closures could leave customers struggling to pay their bills. Which? warned that consumers could be shut out of paying for goods and services unless the UK takes regulatory action to prevent the country moving further toward becoming a cashless society. A new watchdog, with responsibility for overseeing the cash infrastructure, could manage changes to bank branches and intervene when ATMs close, the consumer champion recommended. Data collected by Which? reveals that 488 cashpoints disappeared every month between June and December 2018. 


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FinTech and virtual currencies


UK FinTech investment reaches record levels

Innovate Finance, the independent membership association representing the UK’s global FinTech community, reported that investment in the UK FinTech sector rose by 18% to $3.3b in 2018. The report showed that the UK’s FinTech sector retained its position as a world leader, ranked third globally in venture capital investment behind China and the US, and continued to dominate in Europe. The 2018 FinTech VC Investment Landscape Report, published by Innovate Finance, showed that London continued to be the UK’s preeminent centre for FinTech and suggested that the sector would need to consider how to increase its reach across the UK to tap into the competitive advantage of the wider UK economy.

Distributed ledger technology and large value payments—a global game approach

The Bank of International Settlements (BIS) published details of a lecture given by Mr Hyun Song Shin, Economic Adviser and Head of Research of the BIS, at the University of Cambridge, 22 January 2019. In the lecture, Mr Shin uses global game theory to analyse decentralised payment systems built around blockchain technology. Mr Shin notes payment systems built around distributed ledger technology (DLT) operate by maintaining identical copies of the history of payments among the participant nodes in the payment system. Payment systems based on DLT are compatible with oversight by the central bank, and several central banks conducted successful trials of interbank payments. 


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Sustainable finance


IOPS consults on new guidelines on ESG integration in pension funds

The International Organisation of Pensions Supervisors (IOPS) launched a public consultation on its draft supervisory guidelines on the integration of environmental, social and governance (ESG) factors in the investment and risk management of pension funds. The consultation is open for feedback until 11 March 2019. IOPS is an independent international standard-setting body representing those involved in the supervision of private pension arrangements. Formed in 2004, and supported by the OECD, IOPS 87 members and observers represent 75 jurisdictions and territories worldwide. 


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Dates for your diary





14 February 2019


Markets and trading


The deadline for responses to ESMA’s consultation on future guidelines for money market funds’ disclosure is 14 February 2019.


14 February 2019Regulatory architecture

Trilogue negotiations between the Council of the EU and the European Parliament in relation to proposals to amend the ESFS are scheduled to begin on 14 February 2019.


15 February 2019Payment services

The deadline for responses to the PSR consultation ‘19/1—Draft Specific Direction 4—Competitive procurement of central infrastructure’ is 15 February 2019.


15 February 2019Payment services

The deadline for applications to join the European Payments Council’s new Request-To-Pay Multi-Stakeholder Group is 15 February 2019.


15 February 2019Markets and trading

The deadline for responses to the ICE Benchmark Administration’s survey on the use of LIBOR currencies and tenors to inform its work in seeking the support of globally active banks for the publication of certain LIBOR settings after year-end 2021, is 15 February 2019.


15 February 2019Markets and trading

The transparency requirements for bonds deemed liquid (under ESMA’s bond liquidity assessments) on 31 October 2018 will expire on 15 February 2019.


15 February 2019Brexit

The deadline for EEA data reporting services providers (DRSPs) authorised under MIFID to let the FCA know that they wish to provide data reporting services in the UK after the 29 March 2019 is 15 February 2019.


15 February 2019MiFID II

ESMA will publish double volume cap (DVC) data (as required under MiFIR and originally expected to be published on 7 February 2019) on 15 February 2019.


16 February 2019Markets and trading

The transparency requirements for bonds deemed liquid (under ESMA’s bond liquidity assessments) on 1 February 2019 will apply from 16 February 2019.


18 February 2019Markets and trading

The European Central Securities Depositaries Association (ECSDA) published the updated draft version of the ECSDA CSDR Penalties Framework. This updated draft Framework may be subject to changes and will be presented and discussed with main stakeholders on 18 February 2019 in Frankfurt, Germany.


19 February 2019Payment systems and services

The deadline for feedback to FCA ‘CP18/44: Brexit – Regulatory Technical Standards for Strong Customer Authentication and Common and Secure Open Standards of Communication’ is 19 February 2019.


19 February 2019Sustainable finance

The deadline for responses to ESMA’s consultations on ‘Integrating sustainability risks and factors in the UCITS Directive and AIFMD’ and ‘Integrating sustainability risks and factors in MiFID II’ is 19 February 2019.


20 February 2019Markets and tradingThe deadline for feedback to ESMA consultations on:
21 February 2019Solvency II

The deadline for responses to EIOPA’s call for input on Solvency II reporting and disclosure requirements as part of the 2020 Solvency II review is 21 February 2019.



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About the author:
Prior to joining LexisNexis in 2018, Raphael carried out work placements at Willkie, Farr & Gallagher (sat in Debt Finance) and Macfarlanes (sat in Banking and Finance), through which he was able to gain knowledge about a wide variety of financial products and services. Raphael recently graduated in Law from King’s College London where he took a particular interest in modules such as Finance, Credit & Security and Transnational Company Law. Raphael has also worked as a Paralegal at Axiom Stone Solicitors in Mayfair, where he was involved in a wide range of contentious matters.